4. It is alleged and therefore believed, Defendants DNAG and Deal Jam arecorporations that acquire options to purchase and/or purchase domain names andthereafter sell same to others.5. It is alleged and believed, Defendants, Andrew Miller and PeterHubshman, are owners and principles in both Defendant DNAG and Deal Jam, with aprinciple place of business located at 123 Newbury Street, Second Floor, Boston, MA02116.
At all times relevant hereto Defendant DNAG and Deal Jam acted and/orfailed to act by and through its authorized agents, servants and employees.7. Jurisdiction in the Eastern District of Pennsylvania is based upon 28U.S.C. §1332 as the amount in controversy, exclusive of interest and costs, exceeds$75,000.00 and the parties are citizens of different states.
8. On August 12, 2005, Plaintiff’s authorized agents and Defendants signed aURL Purchase and Sale Assignment Deposit Agreement. A true and correct copy of theURL Purchase and Sale Assignment Deposit Agreement (hereinafter referred to as“Agreement”) is attached hereto, made a part hereof, and marked as Exhibit “A”. TheAgreement was solely drafted by Defendants and/or its Attorneys.9. The Agreement drafted solely by Defendants and/or its Attorneys centeredaround the purchase of the domain name “Sex.Com” as well as a future ConsultingAgreement to be negotiated between the parties.
Case 2:05-cv-05111-BWK Document 1 Filed 09/26/2005 Page 2 of 9